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FIC Directive 8: Requirement to screen employees.

Purpose:

The purpose of this directive is to mitigate the risk of accountable institutions being abused by criminals who are either prospective employees, current employees or by persons that may influence employees.

Applicable Regulation

 

DIRECTIVE 08/2023

Directive For Conduct Within the National Payment System in Respect Of The Financial Action Task Force Recommendations for Electronic Funds Transfers

PCC 55

On Directive 8 Screening of Employees for Competence And Integrity And Scrutinising Of Employee Information Against Targeted Financial Sanctions Lists as A Money Laundering, Terrorist Financing And Proliferation Financing Control Measure

Target

This directive applies to all accountable institutions.

Statutory Requirement

Accountable institutions must:

  1. screen prospective and current employees:
    1. for competence and integrity periodically in a risk-based manner.
    2. against the targeted financial sanctions list
      1. upon notice being given by the Director of the FIC under section 26A(3) of the FIC Act (Notice of a decision of the UN Security Council); and
      2. as and when updates are made to the TFS list.
    3. who are high-risk more using additional screening measures at least once a year.
  2. record in their RMCPs:
      1. the process for screening employees
        1. for competency and integrity.
        2. against the targeted financial sanctions list.
      2. the outcomes of the above-mentioned screening processes.
  3. make available to the FIC or a supervisory body any information mentioned above upon request.
  4. apply Directive 8 and PCC 55 in compliance with applicable labour laws.
Non-compliance

Failure to screen employees according to Directive 8 may result in the imposition of administrative sanctions.

Required Action:

Accountable institutions must have a process for screening current and prospective employees for competence, integrity, and sanctioned status.

This process must be recorded in its RMCP and must be executed using a risk-based approach on an on-going basis.